In March and April, 2015, the Canadian Parliamentary Standing Committee on Health invited international experts to testify about Safety Code 6—Health Canada’s exposure guideline on non-ionizing radiation from cellphones, WiFi, cordless phones, baby monitors, smart meters, and other electromagnetic sources. These doctors, scientists, and researchers almost unanimously denounced Safety Code 6 as outdated and inadequate for protecting the health of Canadians. Below is the testimony presented by Dr. Anthony B. Miller, Canada’s foremost expert in radiation and cancer.

Mr. Chair, members of the committee, thank you very much for giving me the opportunity to present on Health Canada’s review of the evidence for Safety Code 6, which I believe has led to unsafe conclusions.

I am a physician and epidemiologist specializing in cancer etiology, prevention, and screening. I have performed research on ionizing radiation and cancer, electromagnetic fields and cancer, and other aspects of cancer causation. I have served on many committees assessing the carcinogenicity of various exposures, including working groups of the International Agency for Research on Cancer, commonly known as IARC, of which Canada is a member. I was the first Canadian member of their scientific council.

I was a visiting senior scientist in the monographs program in IARC in September, 2011 until January, 2012, where as part of my duties I reviewed the scientific literature that was used by a working group to designate radio frequency fields as a class 2B carcinogen, that is, a possible carcinogen. I was also one of the peer reviewers invited by the Royal Society of Canada to review the draft report of the Royal Society panel on Safety Code 6.

I have a number of concerns over the documents that have recently been released by Health Canada on Safety Code 6 and the document called “Rationale.” What Health Canada has said in its latest iteration of Safety Code 6 is that it should be distinguished from some municipal and national guidelines that are based on socio-political considerations. I find that a strange statement because it seems to provide no room for emerging evidence on health hazards, which surely should be considered if the safety of humans is the objective.

Since the IARC review, which identified radio frequency fields as a possible human carcinogen, there had been a number of studies that have been reported. In my view – and that of a number of colleagues who have written a couple of papers with me on this issue, one of whom will present to you next week – these studies, we believe, reinforce the evidence that radio frequency fields are not just a possible human carcinogen but a probable human carcinogen, putting it in the category 2A. It would be impossible to ignore such a hazard in regulatory approaches.

One of the most important was a study in France, a large case-controlled study, which found a doubling of risk of glioma, the most malignant form of brain tumour, after two years of exposure to cellphones. After five years it was five times the risk. They also identified the fact that in those who lived in urban environments, where there are probably a number of other carcinogens that could impact upon brain tumours, the risk was even higher.

That brings us back to Safety Code 6 and the document that Health Canada contracted to produce a review of the evidence. This was the document produced by the Royal Society panel. I feel that panel was conflicted. As you probably know, the chair changed and the panel had insufficient expertise in epidemiology. My friend, Paul Demers, was called in to be chair of that panel. I believe he presented to you fairly recently. I feel he was put in an impossible situation.

If you read that document carefully, it says that the panel did not have adequate time to do a full review of the data, they therefore relied on reviews of other people and they did not do a detailed evaluation of the studies. That led them, I believe, to false conclusions.

It is important to recognize that there are no safe levels of exposure to human carcinogens. Although risk increases with increasing intensity of exposure, and for many carcinogens, such as tobacco smoke, even more with increasing duration of exposure, the only way to avoid the carcinogenic risk is to avoid exposure altogether. This is why we tend to ban carcinogens from the environment. Asbestos is one particular example of why much effort is taken to get people, particularly young people, not to smoke. Further, we now recognize that people vary in their genetic makeup, and that certain genes can make some people more susceptible than others to the effect of carcinogens. It is those who are susceptible that safety codes should be designed to protect.
As an epidemiologist who has done a great deal of work on breast cancer, one of the most concerning factors that have come to light is a series of case reports, starting with some reports from California and recently with the identification of a similar case in Saskatchewan. In all, there are now seven case reports of women who developed unusual breast cancers in the exact position where they kept cellphones in their bras. These are unusual tumours. They’re multifocal, which means they occur in several places. They seem to mirror where the cellphone was being kept. The radiation from the cellphone seems to have increased in these women the risk, which they presumably already had, of developing breast cancer. They were all relatively young women. This is a most unusual occurrence that must concern us greatly.

We have brain cancers and parotid gland tumours, which are tumours of the salivary gland. There have been several instances of people who have developed this. In Israel recently, a study identified increasing risk of these cancers, particularly with increasing exposure.

Given the long natural history of cancer and the fact that human populations have not been exposed for a sufficient length of time to exclude a carcinogenic effect, it is in my view extremely important to adopt a precautionary approach to the exposure of humans, particularly children, to radio frequency fields. We should note that an individual, if appropriately informed, can reduce their exposure to radio frequency fields from devices that use WiFi, but in the case of cell towers and smart meters, the exposure they receive is outside their control. Then, with the people who manufacture these devices and those who promote WiFi in all sorts of instances, we’re reaching a situation where homes are being saturated with radio frequency fields.

It will be very difficult to prove conclusively an effect. Spread over a large population, if the normal occurrence is relatively rare – and it is relatively rare for brain tumours to occur – even if you double the risk, triple the risk, or even quadruple the risk, it will be difficult to identify that precisely. We need to do these studies.

In the meantime, to avoid a potential epidemic of cancer caused by radio frequency fields from WiFi and other devices, we should strengthen the codes that are meant to protect the public. In my view, Health Canada has not done an adequate job. Safety Code 6, in its current iteration, needs to be re-revised.

Dr. Anthony Miller is Professor Emeritus at the Dalla Lana School of Public Health, University of Toronto. A physician-epidemiologist, he was a member of the scientific staff of the UK Medical Research Council, 1962-71, Director of the Epidemiology Unit of the National Cancer Institute of Canada, 1971-86, Chair of the Department of Preventive Medicine and Biostatistics, University of Toronto, 1992-96, special expert in the Division of Cancer Prevention, US National Cancer Institute, 1997, Senior Epidemiologist, International Agency for Research on Cancer, 1998-99, and Head, Division of Cancer Epidemiology, German Cancer Research Centre, 2000-03.

He is a consultant to the Division of Cancer Prevention, U.S. National Cancer Institute and to the World Health Organization, is Scientific Lead of the Cancer Risk Management Initiative and a member of the Cancer Control Council, Canadian Partnership Against Cancer, Chair, Occupational Cancer Research Centre (OCRC) Scientific Advisory Committee and Member, OCRC Steering Committee.

His research encompasses cancer control, prevention and screening, including the impact of nutrition, radiation and occupation on cancer. Since 1978, Dr. Miller has authored medical publications and books for both medical professionals and the broad general audience. His recent book What Causes Cancer: What We Know and What It Means offers readers a clear and concise overview of the main types of cancer, summarizing data gathered over the history of cancer research from across the globe.

Dr. Anthony B. Miller is the recipient of multiple international awards and honours.